Chaffin v. State
121 So. 3d 608
| Fla. Dist. Ct. App. | 2013Background
- On August 1, 2009, Tyson Chaffin shot and killed his father during a confrontation at their home; Chaffin claimed he acted in self-defense.
- After the shooting Chaffin concealed the body (buried it) and destroyed/cleaned physical evidence; he later confessed at a police station after waiving Miranda rights on videotape.
- The State charged Chaffin with first-degree murder (jury convicted of the lesser included offense of second-degree murder) and one count of tampering with evidence; the information gave no factual particulars for the tampering count.
- At trial the jury heard Chaffin’s confession, witness testimony about the father’s temperament, and officer testimony; the primary factual dispute was whether Chaffin reasonably feared imminent death or great bodily harm.
- Chaffin moved for judgment of acquittal and to suppress his pre-arrest statements; both motions were denied and he appealed on multiple grounds.
Issues
| Issue | Chaffin's Argument | State's Argument | Held |
|---|---|---|---|
| Motion for judgment of acquittal (self-defense) | Evidence insufficient; jury could not reject self-defense | Evidence (confession, inconsistencies, post-shooting concealment, lack of imminent threat) supports conviction | Affirmed — sufficient competent evidence for second-degree murder |
| Motion to suppress confession (Miranda minimization) | Detectives minimized warnings and ignored his question about counsel; waiver not voluntary/knowing | Warnings timely, Chaffin acknowledged understanding and voluntarily waived rights | Affirmed — waiver voluntary; minimization not dispositive because warnings were timely |
| Motion to suppress confession (inquiry re: right to counsel) | His comment "I have a right to an attorney, right?" required officers to stop and answer under Almeida | The comment was not an unequivocal, deliberate question invoking counsel; it was a casual acknowledgement | Affirmed — not an unequivocal invocation requiring cessation |
| Tampering with evidence (single count based on multiple acts) | Charge defective because State presented two distinct incidents (destroying grow-house evidence and burying the body) for one count | State argued the single information covered either act and the jury could convict based on either | Reversed and remanded for new trial on tampering — multiple incidents imperiled jury unanimity (Perley) |
Key Cases Cited
- Romero v. State, 901 So.2d 260 (Fla. 4th DCA 2005) (standard of review for judgment of acquittal)
- Johnston v. State, 863 So.2d 271 (Fla. 2003) (sufficiency and circumstantial-evidence principles for acquittal motions)
- Ross v. State, 45 So.3d 403 (Fla. 2010) (analysis of Miranda voluntariness and effect of minimizing warnings)
- Almeida v. State, 737 So.2d 520 (Fla. 1999) (officers must stop and reasonably answer clear questions about rights during custodial interrogation)
- Perley v. State, 947 So.2d 672 (Fla. 4th DCA 2007) (single-count charging cannot support jury unanimity when multiple distinct incidents are presented)
- Gibbs v. State, 904 So.2d 432 (Fla. 4th DCA 2005) (pointing and firing a gun at victim’s head can satisfy imminently dangerous/depraved mind for second-degree murder)
- Wiley v. State, 60 So.3d 588 (Fla. 4th DCA 2011) (elements defining depraved mind for second-degree murder)
- Sliney v. State, 699 So.2d 662 (Fla. 1997) (evidence supporting voluntary waiver of Miranda rights)
Affirmed in part (second-degree murder and suppression rulings); reversed in part and remanded (tampering count).